Rulings from the Bench

Judge Squatrito rarely makes rulings from the bench. Almost all rulings are by written opinion.

26(f) Reports

Judge Squatrito requires 26(f) Reports in every case and will not set scheduling orders without them. Discovery is completed in most cases between eight and ten months, and the trial memorandum is due within twelve months from the inception of the case.

Resolution by Conference Call

Conference calls may be allowed at the convenience of the parties, especially when out-of-state attorneys are involved.

Dispositive Motions

Discovery

Judge Squatrito allows the parties to start discovery prior to approval of the Rule 26(f) Report. If he receives a motion to compel, he sends counsel an order instructing them to work out the dispute. If the court has to address the issue, the losing party may be sanctioned. This order resolves almost all discovery disputes and he has rarely had to impose sanctions.

Settlement

Judge Squatrito ordinarily does not participate in settlement conferences. Instead, he usually relies on the Magistrate Judges and para-judicial officers.

Trial Preferences

Trial Preferences

Hours of Day for Trial

Trials are scheduled from 8:30 a.m. to 2:00 p.m. There are two twenty-minute breaks during the course of the day.

Days of Week for Trial

Trials are held Monday through Friday.

Time Limitations for Trial

Judge Squatrito takes time estimates seriously as he is very sensitive to the needs of the members of the jury.

Time Limitations for Individual Examinations of Witnesses

Judge Squatrito does not normally limit the time for examination or cross-examination of witnesses.

Opening Statements

Judge Squatrito generally does not allow opening statements.

Closing Arguments

Judge Squatrito usually allows one hour for closing statements, but will make exceptions depending upon the nature of the case.

Demonstrative Exhibits

Judge Squatrito requests that the proposed demonstrative exhibits be brought to the pretrial conference. He will hear objections at that time.

Moving Exhibits into Evidence

Judge Squatrito encourages stipulation with regard to exhibits. Unless objections are made at the pretrial stage, they are deemed waived. All disputes with regard to admission of exhibits should be resolved at the pretrial.

Pre-marking of Exhibits

Judge Squatrito requires that exhibits be pre-marked and exchanged in advance. He prefers the binder format and asks that the original be filed with the clerk. Eight copies should be provided for the jurors, a copy for the law clerk, a copy for the judge, a copy for the witness stand, and a copy/copies for opposing counsel.

Procedural Motions and Arguments

Judge Squatrito directs counsel to raise procedural issues and arguments before or after the trial day or during breaks. Unanticipated disputes are expected to be kept to a minimum.

Objections

Counsel are to state their objections as succinctly as possible, without argument.

Jury Profiles

The clerk's office will make the panel members' questionnaire responses available to counsel on the morning of jury selection.

Jury Selection

Judge Squatrito normally selects juries on the first Tuesday of each month. He uses the strike method with approximately twenty-two to twenty-four venirepeople, and he briefly describes the nature of the case. He has the panel review the questionnaire and then asks members of the panel the voir dire questions proposed by the lawyers. He also allows the lawyers to follow up with any specific questions. He usually allows about a twenty-minute recess during the process, and normally his jury selections take approximately two and a half hours. Juries are picked and stacked for approximately two weeks, and Judge Squatrito allows alternates to deliberate in civil matters.

Jurors in a Civil Case

Juror Notebooks

Juror Notes

Jurors are allowed to take notes.

Jury Charge

Judge Squatrito provides a copy of the charge to the jury.

Post-verdict Communications with Jurors

Judge Squatrito follows Local Rule 83.5 and, as set forth in that rule, he is not inclined to allow jurors to speak concerning the vote or views of other jurors. However, Judge Squatrito would not curtail a juror's right to speak or the public's ability to inquire of a particular juror.

Motions in limine

All Daubert or other motions in limine should be raised in advance of trial, preferably by the final pretrial conference.

Technology

The use of any electronic presentation devices in the courtroom must be requested at the pretrial conference. The judge allows the use as long as it is beneficial to the jury. If technology is used at trial, counsel is still not excused from the preparation of exhibit notebooks for each member of the jury.

Counsel Placement in Court

Judge Squatrito does not require counsel to request permission to move in the courtroom, but does require them to seek the court's permission to approach a witness.